St Ives Retirement Living Whistleblower Policy

1. Purpose and Objective

St Ives is proud of its position in the WA community and is committed to ensuring Employees behave in a responsible, ethical, and trustworthy manner.

St Ives is committed to striving to adhere to the letter and spirit of all applicable laws, codes, standards and regulatory policies and to having internal policies and procedures that promote good corporate governance and ethical behaviour.

St Ives has obligations under various regulations to have adequate provisions in place to enable Employees to disclose information that could have a detrimental effect on the Group.

St Ives has implemented this Whistleblower Policy to ensure that Employees can raise concerns regarding actual and suspected contravention of our ethical and legal standards without fear of reprisal, threats of retaliation or of being disadvantaged in any way by raising the concern.

Employees are expected to first use other internal mechanisms to address issues of concern (refer Whistleblower Procedure) and to use the Whistleblower process when these other mechanisms have failed or may be compromised.

2. Policy Application

This Policy, and supporting procedures, applies to all Employees of St Ives. This Policy does not apply to:

personal work-related grievances unless it has resulted in detriment, or threat of detriment, to the Whistleblower (i.e. an interpersonal conflict between the Whistleblower and another Employee is not covered under this Policy).

3. Reporting of Disclosable Matters

You may make a report under this Policy if you have reasonable grounds to suspect that a St Ives Employee or other person who has business dealings with St Ives has engaged in conduct that constitutes:

dishonest, fraudulent, corrupt or illegal behaviour;

unethical or improper conduct or behaviour;

conduct or an activity that endangers the health & safety of any person;

conduct that is considered a significant danger to the environment;

coercion, harassment or discrimination by, or affecting, an Employee;

a repeated intentional breach of St Ives policy or procedures;

gross mismanagement or misuse of St Ives assets;

conduct that is contrary to the St Ives Code of Conduct;

a breach of any legislation or code relating to St Ives operations oractivities;

improper or misleading accounting and financial reporting practices; or

conduct that compromises the integrity of St Ives systems or the data held inthem.

The process for reporting matters (including persons to whom matters can be reported) is set out in Annexure A.

4. Protection, Anonymity and Confidentiality

If you make a report in accordance with this Policy, you will be entitled to the following protections:

you will be immune from any civil, criminal or administrative legal action (including disciplinary action) for making the disclosure;

no contractual or other remedies may be enforced, and no contractual or other right may be exercised, against you for making the report;

in some circumstances, the reported information is not admissible against you in criminal proceedings or in proceedings for the imposition of a penalty;

anyone who causes or threatens to cause detriment to you or another person in the belief or suspicion that a report has been made, or may have been made, may be guilty of an offence and may be liable for damages;

your identity cannot be disclosed to a Court or tribunal except where considered necessary;

the person receiving the report commits an offence if they disclose the substance of the report or your identity, without your consent, to anyone except ASIC, APRA, the AFP or a lawyer for the purpose of obtaining legal advice or representation in relation to the report; and

you will not be discriminated against or disadvantaged in your employment or engagement with St Ives, even if the report is subsequently determined to be incorrect or not

All reasonable steps will be taken to ensure that you will not be subject to any form of detrimental conduct. Examples include victimisation, discrimination, harassment, demotion, alterations of duties, damage to property or reputation and dismissal or prejudice.

Disciplinary action may be taken against anyone who subjects you to victimisation, discrimination, bias, harassment, demotion, or dismissal as a result of your legitimate reporting of a matter under this Policy.

St Ives will provide the following support if required and appropriate:

connecting you with the Employee Assistance Program;

appointing an independent support person from Human Resources to deal with any ongoing concerns you may have; or

connecting you to third party support providers such as Lifeline (13 11 14) and Beyond Blue (1300 22 4636).

You can choose to remain anonymous or adopt a pseudonym while making a disclosure, over the course of the investigation and after the investigation is finalised. You may refuse to answer questions that you feel could reveal your identity during follow-up conversations.

In instances where a disclosure is made to St Ives via an email address where the identity cannot be determined and the Whistleblower has not identified themselves within the email, St Ives will treat this disclosure as anonymous.

In some circumstances it may be difficult for St Ives to properly investigate anonymous reports.

If authorities take further legal action on the reported matter, it may become necessary for you to identify yourself. If you wish to benefit from statutory protections provided to whistleblowers (for example, under the Corporations Act 2001), you may also have to disclose your name. In these instances, St Ives will continue to ensure that you are protected from reprisal, intimidation, fear or disadvantage.

If you believe your identity has been disclosed, you can immediately report the incident to either the St Ives Group Audit & Risk Chairman or St Ives Group Chairman, (see Annexure Afor contact details), for investigation.

You are encouraged to seek legal advice as you may be entitled to seek compensation and other remedies through the courts if:

you suffer loss, damage or injury because of a disclosure; and

St Ives failed to prevent a person from causing the detriment or did not afford you protections as required by this

This Policy may not protect you if you are also involved in, or connected to, the improper conduct or illegal activity that is being reported.

5. St Ives Obligations and Commitments

St Ives will:

provide this Policy to Employees as part of their onboarding;

provide training to Eligible Recipients in the receiving and handling of disclosures;

undertake general whistleblower awareness training as part of onboarding, and annual refresher training;

provide the mechanisms for an Employee to raise a concern, anonymously if required, with an independent service

It is a condition of employment with, or engagement by, St Ives that all employees, directors, contractor, supplier consultant, agent or the relatives or dependents of any of these comply with this Policy.

This Policy will be made available to officers and Employees through the St Ives intranet and St Ives website.

6. Review of the Whistleblower Policy

The Chief Financial Officer is responsible for administering, implementing and reviewing this policy. This Policy is to be reviewed on a triennial basis or earlier as required.

7. Definitions

Director means a director of a St Ives entity.

Employee includes any

current or former employee of St Ives, including a Director or officer,

contractors, suppliers, consultants, and agents; and

the relatives, dependants or spouses of those individuals referred to at (i) and (ii)

St Ives Group means St Ives Group Pty Ltd., and each of its related bodies corporate and its subsidiaries.

Whistleblower refers to any person who reports a matter under this Policy.

Whistleblower Investigation Officer (WIO) is the Chief Financial Officer St Ives Group Pty Ltd., and or the Group Audit & Risk Committee Chairperson, or independent consultant in cases where there may be a conflict of interest.

Whistleblower Protection Officer (WPO) is the Group Audit & Risk Committee Chairperson, and/or the Chairperson of St Ives Group Board, or independent consultant in cases where there may be a conflict of interest.

Annexure A – Submitting a Whistleblower Report

Step 1 – Consider

Prior to reporting a matter under this Policy, a Whistleblower should consider whether the concern can be more appropriately escalated through:

An Eligible Recipient may direct the Whistleblower to make the report to the external Whistleblower service, or to the WPO, if they consider it appropriate in the circumstances.

Public Interest or Emergency Disclosures

If a Whistleblower Report has been lodged with a regulatory body, the Whistleblower is permitted to make a public interest disclosure to a journalist or parliamentarian in the following circumstances;

At least 90 days have passed since the disclosure was made to either ASIC, APRA or another Commonwealth body;

The Whistleblower does not have reasonable grounds to believe action is being taken;

The Whistleblower has reasonable grounds to believe it is in the public interest to make an additional disclosure; and

Before making the Public Interest Disclosure they have provided written notice to the body to which the previous disclosure was made of their intent to make a Public

An Emergency Disclosure can be made in instances where:

The Whistleblower has previously made a disclosure to ASIC, APRA or another Commonwealth body;

The Whistleblower has reasonable grounds to believe that there is a substantial and imminent danger to the health or safety of people or the natural environment;

Before making the Emergency Disclosure they have provided written notice to the body to which the previous disclosure was made of their intent to make an Emergency Disclosure; and

The information provided in the Emergency Disclosure is no greater than is required to inform the journalist or parliamentarian of the substantial and imminent danger.

Step 3 – Investigation

All complaints through the Whistleblower process, will be managed by the WPO (unless inappropriate or otherwise agreed). If a conflict has been identified in the WPO’s fulfillment of their role, these tasks may be delegated to an alternative senior manager or independent consultant for any particular complaint.

The WPO and WIO will act independently of each other and the responsibilities of these roles will not reside with one person. Investigations will generally be undertaken or coordinated by the WIO. The WIO may use an external investigator to conduct the investigation, either in conjunction with the WIO or independently. The WIO may also use an external expert to assist with an investigation if deemed necessary.

Once a Whistleblower Report is received the WPO will:

Endeavour to commence addressing the matter within 5 business

Assess the risk of detriment to the Whistleblower and provide appropriate

Notify the relevant CEO and Chairs of the board and relevant Board Audit

Consult with the WIO and/or other experts to seek guidance to determine the best way to handle the

Advise the Whistleblower within 5 business days on how it will be investigated (provided the Whistleblower has provided contact information).

Where appropriate, provide regular progress updates on the status of the investigation, at a minimum on commencement of investigation, progress and completion of

The WIO and WPO will keep a secure record of any documents relating to their investigation with access limited to those with a direct involvement in the investigation.

All investigations will be conducted in a fair and independent manner and all reasonable efforts will be made to preserve confidentiality of an investigation.

Any disclosure of content of the Whistleblower Report will only be permitted if:

The Whistleblower consents; or

The disclosure is made to ASIC, APRA, ATO (where relating to a tax matter), the Australian Federal Police, a legal practitioner or a person or body permitted by the Whistleblower Regulations; or

The information does not include the Whistleblowers identity; and

All reasonable steps are taken to reduce the risk that the Whistleblowers identity can be determined from the information; and

It is reasonably necessary for investigating the issues

It is illegal for any person to disclose information that either identifies, or is likely to identify, a Whistleblower outside of the above exceptions.

The Whistleblower is required to keep confidential their report (subject to any legal requirements) to avoid jeopardising an investigation.

The WIO will liaise as necessary with the WPO and will keep the WPO abreast of the progress of the investigation.

The WIO will prepare a report on the outcome of the investigation, making recommendations in relation to the subject of the complaint, and on any remedial action needed to guard against similar future occurrences. The Report will be provided to the WPO, senior management and the St Ives Group Audit & Risk Committee as appropriate. Broader trends identified through Whistleblower Reports will be addressed and mitigated in line with St Ives Risk Management Framework.